Yes, Trinity Industries, Inc. v. United States was a pivotal judicial interpretation most recently heard by the Fifth Circuit Court in July of 2014 with a myriad of issues under deliberation including, but certainly not limited to, Fixed Base Period Percentage Calculations; Consistency Rules; Adhering to the Qualitative Four Part Test under I.R.C. § 41; etc.

Please consult my published article entitled "Recent Judicial Interpretation Provides Guidance on the Research & Experimentation Tax Credit Consistency Provisions " for further coverage at: http://taxconnections.com/taxblog/recent-judicial-interpretation-provides-guidance-on-the-research-experimentation-tax-credit-consistency-provisions/#.U_02zp3D-Uk

Please contact me directly with any further questions and thanks very kindly for submitting your inquiry.